Why a Pre-DOT Audit is Important for Motorcoach Companies
Every bus company should know a DOT audit could come at any time, therefore, it's important to be prepared at all times.
by Amy Nixon
August 2, 2024
Travis L. Brisbon, president and chief transportation officer of Triangle Bus Charters, says having a pre-DOT audit helped his company identify any gaps in their compliance with DOT regulations, allowing them to be proactive in addressing issues.
Photo: Triangle Bus Charters
6 min to read
Every bus company should know a DOT audit could come at any time.
In fact, the audit is sure to come at least once every three to five years. So, waiting until the last minute to prepare for the Department of Transportation to knock at your door may not be the best idea. Especially when you can ensure your preparedness ahead of time.
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What is A DOT Audit?
According to the DOT website, a safety audit is a review of a carrier’s safety data, motor carrier documents, and an interview with the motor carrier’s safety official.
A safety auditor will review documents and assess the carrier’s answers to questions to determine whether they follow regulations and confirm they have basic safety management controls in place.
At a minimum, the auditor will inspect the following:
The DOT’s Safety Measurement System collects and analyzes data from inspections and crash reports from the last two years.
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When a carrier’s safety performance indicates a potential safety risk, an intervention such as a warning letter or investigation may occur, and a safety rating is then given.
When the safety violations and crashes occurred, with recent events weighing more.
The number of buses a carrier operates and the number of vehicle miles traveled.
Acute and critical violations found during investigations.
Once the audit is complete, the Federal Motor Coach Safety Administration will notify the carrier of the results (either pass, conditional, or fail) within 45 days.
A failed audit results in a suspension of the company’s registration effective 15 days after the serve date of the notice, unless the carrier demonstrates within 10 days of the service date of the notice the safety audit contained an error, according to the DOT website.
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If the carrier passes the audit, it will receive its permanent Certificate of Registration after an 18-month provisional period.
Many consulting firms recommend annual Pre-DOT Audits to ensure everything is in place and help prevent fines.
Photo: Triangle Bus Charters
Safety Violations Can Lead to More Problems
Not only can safety compliance issues lead to a failed audit, but they can also lead to the company’s insurance carrier dropping them.
Bus and Motorcoach consulting firm, On Your Mark Transportation’s, CEO Mark Szyperski recalls this happening to one of his clients.
“The insurance company dropped them, and they just had 30 days to find new insurance before they were placed out of business,” Szyperski explains.
On Your Mark Transportation went in and took corrective action, and the company received new insurance. Now, they are returning to help the company prepare for an audit.
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“Having that second set of eyes to look over everything and ensure everything is being done as expected is key,” says Szyperski.
How to Be Better Prepared
Trying to meet and keep up with all the regulations from the DOT can be overwhelming.
It’s not uncommon for some motorcoach companies to focus their energy on maintaining equipment, for example, and then a small unrelated item in the paperwork will get them in trouble with the audit.
A Pre-DOT Audit can help companies ensure they have covered all the bases when it comes time for the actual audit.
Joshua Pratt of BRT Transportation LLC hired a firm for a Pre-DOT Audit.
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“They spent three days with us and went through all our files. Their expertise and counsel had us ready for our audit that was ‘Satisfactory’ with no fines,” he says.
Travis L. Brisbon, president and chief transportation officer of Triangle Bus Charters, says having a pre-DOT audit helped his company identify any gaps in their compliance with DOT regulations, allowing them to be proactive in addressing issues.
“Going through a pre-DOT audit gave us increased confidence in our compliance status, which is particularly important during an official DOT audit,” Brisbon says.
In addition to consulting firms like On Your Mark Transportation and driver safety companies like Smith System, the Department of Transportation has a wealth of information on their auditing process.
Photo: Triangle Bus Charters
Things to Remember
Many consulting firms recommend annual Pre-DOT Audits to ensure everything is in place and help prevent fines.
Being ahead of the game is key. We already know the audit comes at least once every three to five years. And not only does the DOT conduct regular audits, but they also come in for an immediate audit if a driver is involved in a serious accident.
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An outside perspective matters. A fresh set of eyes can often catch small errors that may be otherwise overlooked. Pre-DOT auditors will visit onsite to review all equipment, and physical and digital records and help correct any issues found. From having the correct emergency exit stickers to whether a company’s drug and alcohol testing meets the latest requirements, these Pre-DOT auditors will help ensure your company is set up for long-term success.
Cross your T’s and dot your I’s
If you want to prepare for your Pre-DOT audit, Smith System, a company that provides crash-avoidance driver safety training, suggests that companies utilize the following checklist of things to make sure they are ready to go:
A current copy of the Federal Motor Carrier Safety Regulations.
A current MCS-90 form showing liability insurance coverage that meets the limit required for your operation to protect you if there is a company vehicle accident.
A written drug and alcohol use and testing policy.
Motor vehicle records on every driver.
Proof of CDL insurance for every driver.
Six months of completed driver logs on every driver.
At least 14 months of annual inspections for all operating commercial motor vehicle equipment.
Full maintenance records.
A current DOT security plan.
90 days of post-trip inspection reports for each commercial vehicle where defects have been identified.
Smith System also suggests driver qualification files are always kept up to date. The files should include annual documented reviews of the driver’s certificate of violations, a record of a valid road test, proof the driver’s employment history was checked before hire, training materials on drug and alcohol programs with a signature from the driver, and all instructions to drivers about convictions for moving violations.
Helping companies feel secure is what it's all about Szyperski explains.
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“It is always an honor to work with companies to review their safety information,” he says. “It feels so good to keep companies from being fined by the Department of Transportation for so many little errors. The errors may be small, but the fines can be very large.”
Brisbon says having a Pre-DOT Audit done helped highlight areas where his company could improve efficiency, safety, and overall performance. Plus, it gave confidence in his organization.
“Knowing that your company meets regulatory standards can provide peace of mind to both you and your employees, fostering a culture of safety and compliance,” Brisbon says.
The audit also helped Brisbon streamline his company’s record-keeping practices, making it easier to maintain accurate and up-to-date documentation, he explains.
Cost Savings
Just remember, spending a little money upfront could save you a lot of money in the long run.
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“Spending money on a pre-DOT audit is an investment in your company’s long-term compliance and safety,” says Brisbon. “The cost of noncompliance, including fines, penalties and potential business disruptions can far exceed the cost of a pre-DOT audit.”
A Pre-DOT Audit can also save you from unnecessary stress.
“The reassurance that comes from knowing your company is compliant with DOT regulations is invaluable,” Brisbon said. “It can reduce stress and allow you to focus on other aspects of growing your business.”
Whether you choose to pay for a Pre-DOT audit or not, make sure you are aware of what these audits include so that you can be prepared in advance and avoid costly fines.
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About the Author:On Your Mark Transportation LLC is a consulting firm for the ground passenger transportation industry. This article was written by Amy Nixon, who writes press releases and blog content for their clients.
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